Tlingit Haida Tribal Business Corporation v. OnePromom

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

However, the Amended Complaint alleges that the Employee Handbook contains certain language that does not appear in the document filed by Defendants. Compare [Doc. 24 at ¶¶ 42–47], with [Doc. 34-1]. Because the Court cannot verify the accuracy of the document filed by Defendants, the Court declines to consider it in ruling on the Motion to Dismiss. Case No. 1:25-cv-03285-NYW-MDB Document 49 filed 06/09/26 USDC Colorado pg 3 of 21 at ¶ 90]. Plaintiff alleges that this “legally shareable” “proprietary knowledge” was “confidential and trade secret information and documents that Ms. Combs had obtained and retained from THTBC . . ., and which she used, disclosed, or planned to use or disclose, for or to Combs Consulting’s clients.” [Id. at ¶ 93]. In August 2025, Ms. Combs began working for CBRE Government & Defense Services, a direct competitor of THTBC. [Id. at ¶¶ 105–06]. THTBC initiated this action on October 17, 2025, [Doc. 1], and filed the Amended Complaint on February 6, 2026, [Doc. 24]. It asserts eight claims: (1) a breach of contract claim against Ms.